Privacy Policy.

Overview

The Oak Companies. (collectively, “Oak Companies”, “we”, “our”, or “us”) is committed to protecting the privacy of our customers and others interested in our business and investment services, including via interactions with our website (the “Site”, collectively offering, the “Services”).

This Privacy Policy (“Privacy Policy”) applies to information from the Services that collect personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, as defined by applicable privacy laws (“Personal Information”). Personal Information does not include: (i) publicly available information; (ii) deidentified or aggregated consumer information, as permitted under applicable laws; or (iii) personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FRCA”) and the Gramm-Leach-Bliley Act (“GLBA”). For more information on information collected, processed, or disclosed pursuant to the GLBA and its implementing regulations, please refer to our GLBA Privacy Notice https://www.oakrepartners.com/privacy-policy/.

By accessing and using the Site containing a link to this Privacy Policy, applying for the Services, or otherwise providing us with Personal Information, you agree to the terms and conditions of this Privacy Policy. If you do not agree to the terms and conditions of this Privacy Policy, then please do not provide us with your Personal Information. Please note, however, that if you choose to limit the information that you provide to us while using the Services, you may not be able to use or participate in certain features of the Services.

1. Revisions and Updates to this Privacy Policy

We reserve the right to revise or update this Privacy Policy at any time, and you should periodically read the Privacy Policy to learn of any revisions or updates. If the revision or update is material, we will provide you notification via email or banner on the Site; however, for non-material revisions or updates, we will notify you by posting the revised or updated Privacy Policy and its “Last Modified Date” on the Site. Using the Services thereafter constitutes your agreement to and acceptance of the Privacy Policy and its revisions or updates.

2. The Types of Personal Information That We Collect

Oak Companies collects Personal Information regarding customers who visit the Site, initiate an application process, register for marketing or communication services, or submit inquiries about the Services (collectively, “you”, “your”). We collect Personal Information about you in various ways, including:

• Directly from you; and
• From third parties.

Personal Information from you directly or via third parties.

We collect Personal Information directly from you, for example when you submit an inquiry via the Site or initiate an application for the Services. We collect Personal Information from third parties including our Affiliates and Subsidiaries, data providers, and financial bureaus where permitted by law and in the course of providing the Services you request. You agree that the third-party providers of data, not Oak Companies, are responsible for maintaining your information with proper and sufficient accuracy and authority in accordance with all governing laws and regulations. We make no effort to verify any information for any purpose, including accuracy, legality, or non-infringement that we properly receive from third parties.

We may collect the following categories from the above-mentioned sources:

• Identifiers, including name, alias, telephone number, postal address, unique personal identifier, online identifier, email address, account name, financial and bank information, social security number, driver’s license number, passport number;
• Protected Classifications, including age, national origin, citizenship and marital status;
• Professional or Employment Information, including current or past job history; and
• Sensitive Personal Information, including social security number, driver’s license number, passport number, national origin and citizenship.

Special Category Information

Some of the information that we may collect as a result of providing investment solutions is particularly sensitive (e.g., social security number, driver’s license number, passport number, national origin and citizenship). We only collect this information as provided by or consented by you. Such sensitive information is only shared for the purpose of providing the Services you request or as consented for and will not be shared or used by us for any other purposes.

3. Purpose of Collection

Oak Companies processes Personal Information for the following purposes:

• Provide the Services. We may use your Personal Information to provide the Services or any other products or services you may request from us.
• Monitor the Services. We collect your Personal Information for monitoring purposes to help us diagnose problems with our servers, administer and troubleshoot the Services, calculate usage levels, analyze industry standards, and analyze transactions, trends, and statistics regarding the use of the Services.
• Personalize your Experience. We may collect your Personal Information to leverage analytics and retargeting to personalize your experience.
• Respond to Inquiries and Fulfill Requests. We may use your Personal Information to respond to your inquiries and to fulfill your requests for information.
• Communicate with You. We may use your Personal Information to send you marketing information about the Services and other items that may be of interest to you.
• Improve the Services. We may use your Personal Information to make the Site more stable and user-friendly, to analyze service issues, improve the design and content of the Services, analyze how the Services are used, offer new services, and to develop new marketing programs relating to the Services.
• Customer Service. We may use your Personal Information when contacting you regarding customer service, the Services, or in response when you provide feedback. We may also use your information to send administrative emails regarding the Services or to inform you of any changes to this Privacy Policy, our Terms, or our third-party partner’s Terms.
• Support Business Operations. We may use your Personal Information to support our internal and business operations, including marketing, security, and advertising.
• Enforce Agreements. We may use your Personal Information to enforce separate agreements between you and us, enforce this Privacy Policy, our Terms and Conditions, or our third-party partner’s terms, or in connection with a transaction with a similar effect.
• Fulfill Other Purposes. We may use your Personal Information to fulfill: (a) any other purpose for which you provide it; (b) any legal or regulatory requirements and any of our internal policies; (c) other purposes disclosed at the time of collection; (d) any other purpose with your consent; and (e) any other purposes set forth in this Privacy Policy.

4. Disclosure of Personal Information

We do not sell, share, rent, or otherwise disclose the Personal Information collected from the Services or on the Site, to third parties for monetary or other valuable consideration, unless otherwise stated below or with your consent or your agent’s consent on your behalf:

• Service Providers & Contractors. We may share your Personal Information with service providers and contractors to perform tasks on our behalf and to assist us in providing the Services, including but not limited to internal and business operations, security, identity verification, and related services. Service providers and contractors may use the information only as necessary to provide the services to us and are contractually required to keep your information confidential and secure.
• Investment and Business Partners. We may share your Personal Information with our investment and business partners to provide you with the Services you have requested. We may also share your personal information to business partners with whom we jointly offer the Services.
• Authorized Representatives. If another individual is managing your account or access to the Services on your behalf (for example, a wife managing the account of her husband), as authorized by you or as a personal representative under applicable law, that person can view all Personal Information about you in the Services.
• In the Event of Merger, Sale, Divestitures or Change of Control. We may transfer or assign Personal Information to an entity that acquires or is merged with us as part of a merger, acquisition, sale of ownership or assets, or other change of control.
• Other Third Parties with your Consent. We may disclose Personal Information to other third parties to whom you or your agents authorize us to disclose your personal information in connection with the Services we provide to you.
• Other Disclosures. We may disclose your Personal Information if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our contracts with you, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to our, your, or third parties’ rights, property, or safety.

We may share de-identified and/or aggregate analytics with third-party partners about how users interact with the Services, including usage patterns for certain programs, content, services, advertisements, promotions, and/or functionality available through the Services.

5. Transfer of Personal Information to a Third Country

If you do not reside in the United States and provide Personal Information to us, please note that your Personal Information will be transferred, processed, collected, used, accessed and/or stored in the United States and subject to U.S. laws. The laws in the United States may not provide the same protections for your Personal Information as the jurisdiction in which you are located. Do not provide your Personal Information to us if you do not want this information to be transferred or processed outside of your country, or if the laws in your country restrict such transfers.

6. Retention Period

We keep your Personal Information only as long as necessary to provide you with the Services and for legitimate and essential business purposes, such as maintaining the performance of the Services, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes.

7. Third-Party Site

The Services may link to third-party websites, online services, mobile applications and/or contain advertisements from third parties that are not affiliated with us and which may link to other websites, services, or applications. Please be aware that we are not responsible for the privacy or practices of other websites or third parties, including those using the Oak Companies branding. We do not make any guarantee regarding those third-party websites, services, or applications, and we are not liable for any loss or damage caused by the use of such sites. Any data collected by third parties is not covered by this Privacy Policy. You should review the policies of the third parties and contact them directly if you have any questions about their services or practices.

8. Confidentiality and Security

We maintain appropriate safeguards using industry standard technology to heighten the security, accuracy, and privacy of any Personal Information we have collected, and we have put in place reasonable precautions to protect information from loss, alteration, and misuse. While we implement these measures, please note that 100% security is not possible, and we cannot guarantee that the security measures we have in place to safeguard Personal Information will never be defeated or fail, or that those measures will always be sufficient or effective.

9. Minors

We do not knowingly collect or solicit personal information from children under the age of 18 without consent from a guardian or parent. By using the Site or Services, you represent that you are at least 16 years old or have consent from a guardian or parent. If we become aware that we have inadvertently received or collected Personal Information from a user of the Site who is under the age of 18, we will attempt to immediately delete that information from our files and records. If you believe a child who is under the age of 18 has provided us with Personal Information without consent from a parent or guardian, please contact us using the information below.

10. Contact Us

If you have any questions or concerns in connection with Oak Companies’ information collection practice summarized in this Privacy Policy, please send an email, with the subject heading “Privacy Policy Question,” to ir@oakrepartners.com. In the email, please state your questions or concerns.

If you have any questions about the Services, please contact us at 980.288.6627.